NFPA 70E – The FRC Daily Wear Conundrum

During the last 10 years I’ve taught quite a few courses on NFPA 70E. By far, the biggest area of pushback and resistance deals with my recommendation that qualified persons wear hazard risk category (HRC) 2 flame resistant (FR) clothing as daily wear. The common complaint is that FR clothing is hot and employees don’t want to wear long-sleeve shirts during Summer months. Frequently, I have students remark that they rarely work on exposed energized equipment. Many clients comments that whenever they work on exposed energized equipment they will have their workers don the FR clothing to perform the task and then will remove the  clothing once the task is completed. If you have qualified persons, are you aware the following tasks typically require FR clothing:

  • Troubleshooting with an electrical multimeter
  • Performing verification of deenergized condition with a multimeter
  • Removal of bolted covers to expose bare, energized electrical conductors and circuit parts   

In addition, although circuit breaker or fused switch operation does not typically require FR clothing, NFPA 70E still requires nonmelting long sleeve shirt and pants.

Every time a qualified person perform a HRC task 1 and above, FR clothing is required. Even resetting a circuit breaker will require a long sleeve shirt and pants. I don’t believe it is practical that a qualified person will don the FR clothing every time it is required. What if a worker is troubleshooting an HVAC unit on the roof? How about troubleshooting a downed machine while the plant is losing thousands of dollar an hour in lost production and the FR clothing is 100 yards away?

Wearing FR HRC 2 clothing as a daily uniform helps ensure qualified persons are protected from arc flashes. Otherwise, you will liekly face an administrative nightmare trying to enforce the “don as you go” FR policy.


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